Requirements for Awarding Credit and Appropriate Grade Placement

The purpose of this letter is to address state requirements for awarding credit and placing students in an appropriate grade. Most importantly, I want to remind school districts and charters of their statutory responsibilities to confer credit and graduate students based on demonstrated mastery of the state curriculum standards. Additionally, I am calling on local school boards and administrators to review existing policies to ensure that students are receiving credit promptly, are only receiving credit for demonstrating mastery of the state curriculum standards, and are taking the appropriate assessments for the courses in which they are enrolled.

Some districts have been investigated by state and federal authorities for a variety of practices that had the effect of deferring some students’ promotion from 9th to 11th grade (skipping 10th grade) to avoid accountability for 10th grade test results under the No Child Left Behind Act. Several districts followed local policies that placed all students from foreign countries in ninth grade disregarding credits earned on their foreign transcripts. Schools have also granted students credits through completion of short-term programs with insufficient evidence of whether students have mastered the subject matter.

It is my intention to provide detailed clarification regarding the issues described above. This clarification will enable district officials to determine whether they have policies or programs that fail to award credit or graduate students based solely on academic considerations and, if needed, to take appropriate action in response to those determinations.

State Board of Education rule requires that student transcripts be evaluated and students be placed “promptly in the appropriate grade and/or subjects.” There is no excuse for taking an entire semester or school year to award credits to which a new student is entitled.

While some students may benefit from a provisional placement to determine whether to accept a credit awarded by an educational system with which the district is not familiar, students do not benefit from deferring a final decision through an entire semester or school year. All districts and charters should be able to evaluate a transcript and appropriately place a student within 30 days of enrollment.

School administrators and school boards across the state should evaluate whether they have a policy in place to promptly evaluate credits earned and correctly place a student in the appropriate grade within 30 days of enrollment. School administrators should also determine that no students are misclassified during the 2013-2014 school year due to past practices that unreasonably deferred recognition of transfer credits.

School administrators and school boards should also carefully review their credit recovery and other credit award programs that allow students to catch up for lost instruction. These types of programs can be a valuable tool to help some students remain on track to graduate. However, a program that confers credits in a very short period of time with no evidence to demonstrate student learning does not serve the best interest of the student.

The state law governing both of these issues is clearly stated in Section 28.021 of the Texas Education Code: “A student may be promoted only on the basis of academic achievement or demonstrated proficiency of the subject matter of the course or grade level.”

Recent events have highlighted a need for more active investigation by the Texas Education Agency of district-reported data that are used in a variety of state and federal systems, including accountability, monitoring, and financial systems. I am focusing additional resources to pursue allegations of dishonesty in reporting student data and administering state assessments.

The agency is currently analyzing course completion data and State of Texas Assessments of Academic Readiness (STAAR) end-of-course student assessment data as part of 2013 Student Assessment Data Validation to ensure districts are administering the required end-of-course assessments to their students. Based on this analysis, some districts may be contacted and asked to explain discrepancies in their data.

My expectation is that districts and charters will—in keeping with our tradition of local control by an elected school board—resolve locally any identified issues relating to the requirements for awarding credit and appropriate grade placement.

I also wish to be clear that the agency will not tolerate attempts to manage student classification or credit award in a manner that circumvents accountability to the state.

Texas educators are asked to take on challenging responsibilities as our education system and overall society have become more complex. The challenge continues as statutes and regulations are added and changed every two years at the state level and at least as frequently at the federal level. Despite those demands and responsibilities, educators and their school boards cannot lose sight of our public schools’ core mission to provide each student with the opportunity to learn the state curriculum, receive appropriate credit, and earn a diploma that represents the appropriate education provided for under Texas law.

I appreciate your dedication to Texas students and your cooperation in ensuring that our students receive the education they deserve.